20170915PAC to Staff 14-19 21.pdf

ROCKY MOUNTAIN
POWER
A DIVISION OF PACIFICORP 1407 W North Temple,Suite 330
Salt Lake City,Utah 84116
September 15,2017
Diane Hanian
Idaho Public Utilities Commission
472 W.Washington
Boise,ID 83702-5918
[e-mail] (C)
RE:ID PAC-E-17-07
IPUC 16 Set Data Request (1-47)
Please find enclosed Rocky Mountain Power's Responses to IPUC 16'Set Data Requests 1.1-
1.47.Also provided on CD is Attachment IPUC 2-1.Provided on the enclosed CD are
Confidential Attachments IPUC 2-2,15,22,and 33 and Confidential Responses IPUC 14,19 and
21.Responses to IPUC 13,16,24,29 and 34-47 will be provided under separate cover.
Confidential information is provided subject to the terms and conditions of the protective
agreement in this proceeding.
If you have any questions,please feel free to call me at [phone].
Sincerely,
J.Ted Weston
Manager,Regulation
Enclosures
C.c.:Diane Hanian/IPUC [e-mail] (C)
Ronald L.Williams/PIIC [e-mail]
Jim Duke/PIIC [e-mail] (W)
Kyle Williams/PIIC [e-mail](W)
Val Steiner/PIIC [e-mail] (W)
Brian C.Collins/Brubaker &Associates [e-mail] (C)(W)
James R.Smith/Monsanto [e-mail] (C)(W)
Maurice Brubaker/Monsanto [e-mail] (C)(W)
Katie Iverson/Monsanto [e-mail] (C)
Eric Olsen/IIPA [e-mail](C)
AnthonyYankel/IIPA [e-mail] (C)
Randall C.Budge/Monsanto [e-mail] (C)
Thomas J.Budge/Monsanot [e-mail] (C)(W)
PAC-E-17-07 /Rocky Mountain Power
September 15,2017
IPUC 16'Set Data Request l
IPUC Data Request 1
Please provide work papers,exhibits,tables,and any analysis supporting the
Company's filing in electronic format with formulae intact with references to
sources for all pasted values.
Response to IPUC Data Request 1
These documents were provided at the time of filing on CD.
Recordholder:Kaley McNay
Sponsor:Not applicable
PAC-E-17-07 /Rocky Mountain Power
September 15,2017
IPUC 16*Set Data Request 2
IPUC Data Request 2
Please provide copies of all past and future data requests and responses received
by or sent from Rocky Mountain Power to any party in related applications
submitted in other state jurisdictions.Please include both formal and informal
responses.In addition to requests made in Idaho,please provide copies of
PacifiCorp's responses to new wind and transmission data requests submitted by
all parties in the states of Utah,Washington,Oregon,Wyoming,and California.
This response should include public and confidential data responses.Please
provide all future responses at,or shortlyafter,the time when the Company files
its responses to other parties'requests.As responses are provided,please include
a summary of the state name,organization and DR#s for the DRs contained
within each response.
Response to IPUC Data Request 2
Please refer to Attachment IPUC 2-1 and Confidential Attachment IPUC 2-2.
IPUC will be copied on all future responses in the other proceedings as
SupplementalResponses to this data request.
Confidential information is provided subject to the terms and conditions of the
protective agreement in this proceeding.
Recordholder:Kaley McNay
Sponsor:Not applicable
PAC-E-17-07 /Rocky Mountain Power
September 15,2017
IPUC lst Set Data Request 3
IPUC Data Request 3
Please provide a list of all regulatory authorizations required for the project.
Please identify the authorizations,if not obtained,that would cause the Company
to cancel or modify the project,and explain why it would affect the project and
specifically what action the Company would take.
Response to IPUC Data Request 3
The Company is currentlyengaged in the followingregulatory dockets with the
potential to impact project implementation approach and outcomes:
Docket LC 67-The 2017 Integrated Resource Plan (IRP)docket pending
before the Public Utility Commission of Oregon (OPUC).OPUC review
and acknowledgementof the 2017 IRP Action Items pertaining to the new
wind and transmission projects is pending.
Dockets UM 1845 and 17-035-23-The 2017R Request for Proposals
(2017R RFP)dockets in the states of Oregon and Utah,respectively.
Case No.PAC-E-17-07-Applicationfor a Certificate of Public
Convenience and Necessity (CPCN)and binding ratemaking treatment for
new wind and transmission facilities before the Idaho Public Utilities
Commission.
Docket 20000-520-EA-17-Application for a CPCN and nontraditional
ratemaking for wind and transmission facilities before the Wyoming
Public Service Commission (WPSC).
Docket 17-035-40-Applicationfor approval of a significant energy
resource decision and voluntaryrequest for approval of a resource
decision before the Utah Public Service Commission.
The primary risk in maintaining the critical-path construction schedule for the
Transmission Projects is the on-going regulatory review and approval processes
currentlyunderway.In particular,it is critical that PacifiCorp obtain a CPCN
from the WPSC for the Transmission Projects,which are conditioned upon
acquisition of all necessary rights-of-way,with sufficient time to meet this
condition.If the Company receives CPCNs later than the first quarter 2018,it will
have an opportunityto assess the viabilityof achieving a year-end 2020 online
date for the Transmission Projects before spending significant capital.If the
Company receives CPCNs from the WPSC,it plans to complete construction over
two construction seasons (2019 and 2020)and,based on its experience in building
other significant transmission projects,is confident that the Transmission Projects
will be operational by the end of 2020.
Recordholder:Ted Weston
PAC-E-17-07 /Rocky Mountain Power
September 15,2017
IPUC 16'Set Data Request 3
Sponsor:Jeff Larsen
PAC-E-17-07 /Rocky Mountain Power
September 15,2017
IPUC 16*Set Data Request 4
IPUC Data Request 4
Please provide all information since the last depreciation study supporting the
Company's basis for a 30-year depreciation life of the wind turbine generators
(i.e.,manufacturer data or studies).
Response to IPUC Data Request 4
The Company has not developedadditional information regarding the appropriate
depreciation life for the wind turbine generators since the last depreciation study.
However,the Company intends to do complete studies to inform the Company's
depreciation study that will be filed with the Idaho Public Service Commission in
September 2018.
Recordholder:Kent Ipson
Sponsor:Tim Hemstreet
PAC-E-17-07 /Rocky Mountain Power
September 15,2017
IPUC 16'Set Data Request 5
IPUC Data Request 5
Please explain all IRS requirements needed by the Company to receive 100%of
the PTC's related to PAC-E-17-07 projects.
Response to IPUC Data Request 5
The Company assessed each of the relevant criteria for qualifyingthe proposed
new wind projects for the full value of available production tax credits (PTCs)
consistent with applicable Internal Revenue Service (IRS)guidance.This
assessment included:(1)whether the 2016 safe-harbor purchases from the turbine
vendors are sufficient to satisfy the five-percent safe-harbor for new facilities
(Section 6 of IRS Notice 2016-31);and (2)whether the projects will be able to be
placed into service by the end of the fourth calendar year followingthe year
construction began (i.e.,December 31,2020 for construction that began in 2016)
consistent with the four-year continuitysafe-harbor (Section 3 of IRS Notice
2016-31.
Recordholder:Jonathan Hale
Sponsor:Chad Teply
PAC-E-17-07 /Rocky Mountain Power
September 15,2017
IPUC lst Set Data Request 6
IPUC Data Request 6
Please detail all IRS requirements the Company has completed to date by project
site in order to qualify for 100%of the PTC's referenced by PAC-E-17-07.
Response to IPUC Data Request 6
Internal Revenue Code (IRC)section 45(a)provides for a current production tax
credit (PTC)for 2017 in the inflation-adjusted amount of 2.4 cents per kilowatt-
hour (¢/kWh)of wind electricity produced for wind facilities for which
construction begins before January 1,2017.This is known as the 100 percent PTC
amount.IRS Notice 2013-29 Section 5 and 2016-31 Section 6 provide that if five
percent or more of the total cost of a new wind facility is incurred before
January 1,2017,then the wind facility will be deemed to be under physical
construction before January 1,2017 and therefore qualify for the 100 percent
PTC.Please refer to the Company's response to IPUC Data Request 9 for more
information regarding the five-percent safe harbor.
Recordholder:Jonathan Hale
Sponsor:Chad Teply
PAC-E-17-07 /Rocky Mountain Power
September 15,2017
IPUC lst Set Data Request 7
IPUC Data Request 7
Please detail all remaining IRS requirements by project site which the Company
has yet to complete in order to qualify for 100%of the PTC's referenced by
PAC-E-17-07.
Response to IPUC Data Request 7
Internal Revenue Service (IRS)Notice 2016-31 provides that the continuity
requirement of continuous physical construction must be met.Section 3 of the
Notice provides that the continuityrequirement will be met if the wind facilities
are placed in service no later than the end or the fourth calendar year following
the calendar year that physical construction began.Accordingly,all project sites
are using the five-percent safe harbor to establish that physical construction began
before January 1,2017.Therefore,to qualify for the four-year continuitysafe
harbor,the project sites must achieve commercial operationby December 31,
2020.
Recordholder:Jonathan Hale
Sponsor:Chad Teply
PAC-E-17-07 /Rocky Mountain Power
September 15,2017
IPUC 1st Set Data Request 8
IPUC Data Request 8
In reference to Company witness Teply'stestimony on page 7,please provide the
documentation,by Wind Project,showing that the Company has met the "start of
construction"requirement,and the "safe harbor"requirement for the PTCs.
Include all source documents including receipts,journal entries,emails,contracts,
and any other documents for the purchases and acquisitions for the Wind Projects
before December 31,2016.
Response to IPUC Data Request 8
The Company's calculation of the five-percent safe harbor and the associated
support materials for its proposed new Wind Projects are considered to be highly
confidential and commercially sensitive.The Company requests special
handling.Please contact Ted Weston [phone] to make arrangements for
review.
Recordholder:Chad Teply
Sponsor:Chad Teply
PAC-E-17-07 /Rocky Mountain Power
September 15,2017
IPUC 16*Set Data Request 9
IPUC Data Request 9
Please explain the Company's approach to meet IRS Safe Harbor eligibility
including start of construction,continuityand any other provisions.
Response to IPUC Data Request 9
The Company's proposed Wind Projects will meet the start of physical
construction requirement through the use of the five-percent safe harbor as set out
in Internal Revenue Service (IRS)Notice 2013-29 Section 5 and IRS Notice
2016-31 Section 6.
The Company intends to the meet the continuityof physical construction under
the continuitysafe harbor provision of IRS Notice 2016-31 Section 3 by placing
the wind facilities into service by December 31,2020.
Please also refer to the Company's response to IPUC 8.
Recordholder:Chad Teply
Sponsor:Chad Teply
PAC-E-17-07 /Rocky Mountain Power
September 15,2017
IPUC 161 Set Data Request 10
IPUC Data Request 10
If the Company does not meet the December 2020 completion project date,please
describe in detail the Company's contingency plans to obtain 100%eligibilityof
PTCs.
Response to IPUC Data Request 10
The Company's intent is for competitively procured transmission and new wind
projects to meet the December 2020 completion date.The Company has not
developed specific contingency plans to obtain 100 percent eligibilityof
production tax credits (PTCs)if ultimatelyselected wind projects or individual
wind turbines are not placed into commercial operation by December 31,2020.
However,assuming a delay in wind turbine commercial operation were due to
transmission projects that were not completed by December 31,2020,and the
transmission projects were not delayed by any action of the Company,then the
Company would expect wind turbines completed,demonstrated as functional,and
placed in service (in accordance with Internal Revenue Service (IRS)guidance)
before year-end 2020 would be eligible for 100 percent of the PTCs.Based on
the particular facts and circumstance in Private Letter Ruling (PLR)20033403,
the IRS ruled that if a wind turbine has all necessary operating permits and
licenses,has been synchronized to the power grid,the critical tests for the
components of the wind turbine have been completed,the wind turbine has been
placed in the control of the taxpayer by the contractor and the taxpayer has sold
electricity that has been produced by the wind turbine,then the wind turbine has
been placed in service.This is even if the wind project is not producing
transmission-level electricity due to a delay in a transmission project and has not
been deemed to be under commercial operation by a regulatory commission.A
PLR may not be relied on as precedent by other taxpayers,but it is indicative of
the IRS position on certain matters.
Alternatively,IRS guidance also provides certain provisions for wind projects to
demonstrate PTC eligibilitythrough certain "start of construction"and
"continuous construction"parameters,which would be assessed by the IRS on a
case-by-case basis,but may also allow 100 percent PTC eligibilityto be
maintained with an in-service date beyond December 31,2020,as a contingency
consideration.
Recordholder:Jonathan Hale
Sponsor:Chad Teply
PAC-E-17-07 /Rocky Mountain Power
September 15,2017
IPUC 16'Set Data Request 11
IPUC Data Request 11
The Company has provided economic analysis of the project assuming 100%
eligibilityand receipt of the PTCs.Please provide similar analysis of the project
if full receipt of the PTC is not met (i.e.80%,60%,and 40%).
Response to IPUC Data Request 11
The Company objects to this request as requiring developmentof a special study
or information not maintained in the ordinary course of business.Without
waiving this objection,the Company responds as follows:
PacifiCorp has not performed the requested analysis.Please refer to the
Company's responses to IPUC Data Request 10 and IPUC Data Request 12.The
Company has identified the contribution of 100 percent of the production tax
credits (PTCs)from the assumed procurement of 860 megawatts (MW)of new
wind resources in its economic analysis.Please refer to the rows "New Wind
PTCs"in Link Exhibit No.25,which shows that 100 percent of the PTCs
contribute $795 million in present-valuebenefits in each price-policy scenario.
The effect of reduced PTC benefits can be estimated by applying a percentage
adjustment to the PTC benefits included in the Company's economic analysis.
Recordholder:Randy Baker
Sponsor:Rick Link
PAC-E-17-07 /Rocky Mountain Power
September 15,2017
IPUC 16*Set Data Request 12
IPUC Data Request 12
With respect to the previous question,please quantifythe likelihood of not
receiving 100%of the PTC.
Response to IPUC Data Request 12
The Company has not quantified the likelihood of not receiving 100 percent of the
production tax credits (PTCs),but such a result is highly unlikely.The Company
intends to receive 100 percent of the PTCs by ensuring that the safe-harbor
requirements have been demonstrated,timely regulatory reviews and rights-of-
way acquisition are facilitated,project implementation schedules are effectively
managed,and the projects have been placed in service by December 31,2020.
Recordholder:Chad Teply
Sponsor:Chad Teply
PAC-E-17-07 /Rocky Mountain Power
September 15,2017
IPUC 13'Set Data Request 14
IPUC Data Request 14
Please provide the average yearlymarket price of wind RECs over the past five
years,in addition to the projected value of these RECs over the next 10 years.
Confidential Response to IPUC Data Request 14
There is no published price index for renewable energy credit (REC)markets.
Most transactions are conducted as bilateral contracts between parties,and prices
are not reported.The REC market is not consistently active and is illiquid.There
is little price transparency in REC markets.Please refer to Confidential
Attachment IPUC 14,which provides the average yearlysale price of the RECs
sold by PacifiCorp.
Due to lack of transparency and liquidityin the REC markets,the Company
maintains only a one-year forecast for REC sales.
Confidential information is provided subject to the terms and conditions of the
protective agreement in this proceeding.
Recordholder:Tuba Avcisert
Sponsor:Rick Link
PAC-E-17-07 /Rocky Mountain Power
September 15,2017
IPUC 16'Set Data Request 15
IPUC Data Request 15
Please provide the Company's Project Plan includingbut not limited to:
(a)A detailed schedule/Ganttchart reflecting all major activities on the critical
path.
(b)Any contingency plans the Company will implement to recover from delays.
(c)Project risks,the likelihood of these risks,and costs associated with those
risks.
Response to IPUC Data Request 15
Wind Projects
(a)Indicative project-execution schedules were provided as sub-exhibits to the
Direct Testimony of Company witness,Chad A.Teply,specifically sub-
exhibits to Confidential Exhibit No.1,Confidential Exhibit No.2,and
Confidential Exhibit No.3:Confidential Exhibit No.1-6,Confidential Exhibit
No.2-6,and Confidential Exhibit No.3-6.
(b)The Company is implementing a strategy of ongoing engagement with
stakeholders includingpermitting agencies,local authorities and property
owners to identify risks and develop mitigation plans.Concurrent and
collaborative delivery of design and permitting is tailored to reduce the
potential for delays in subsequent project phases.Construction contracts will
have guaranteed milestones and liquidated damages included to motivate
contractors to complete the project on time.Contractors will be empowered to
use whichever method(s)they feel appropriateto recover any schedule delays.
(c)Case-by-case project risks will continuallybe identified,assessed,monitored
and mitigated to maintain project schedule and cost.Beyond consideration of
traditional project implementation risks in project development and planning
activities to date,no stand-alone quantification or probability analysis of
specific project risks has been compiled to date.
Transmission Projects
(a)A Gantt chart for the project schedule was included in the Direct Testimony of
Company witness,Rick A.Vail,specifically Exhibit No.13.
(b)The Company has developedan ongoing strategy of engagement with
stakeholders includingpermitting agencies,local authorities and property
owners to identify risks and develop mitigation plans.Concurrent and
collaborative deliveryof design and permitting is tailored to reduce the
PAC-E-17-07 /Rocky Mountain Power
September 15,2017
IPUC 16*Set Data Request 15
potential for delays in subsequent project phases.Construction contracts will
have guaranteed milestones and liquidated damages included to motivate
contractors to complete the project on time.Contractors will be empowered to
use whichever method(s)they feel appropriateto recover any schedule delays.
(c)The risk/uncertaintyassessments are considered commercially sensitive and
highly confidential.The Company requests special handling.Please contact
Ted Weston at [phone] to make arrangement to review.Please refer to
Confidential Attachment IPUC 15,which provides a copy of the summary
project plan.
Confidential information is provided subject to the terms and conditions of the
protective agreement in this proceeding.
Recordholder:Chad Teply,Todd Jensen,Stuart Smith
Sponsor:Chad Teply and Rick Vail
PAC-E-17-07 /Rocky Mountain Power
September 15,2017
IPUC 16'Set Data Request 17
IPUC Data Request 17
Please provide the transmission capacity and the monthlypercent utilization for
the existing line segment between Aeolus and Jim Bridger.
Response to IPUC Data Request 17
The Company objects to this request as vague,ambiguous,not reasonably
calculated to lead to the discovery of admissible evidence,and requiring
development of a special study or information not maintained in the ordinary
course of business.Without waiving these objections,the Company responds as
follows:
Aeolus is a planned substation that does not yet exist.Thus,there is no existing
transmission between Aeolus and Jim Bridger.However,if the intent is to report
on east Wyoming transmission usage,please refer to the Company's response to
IPUC Data Request 18.
Recordholder:Jamie Austin
Sponsor:Rick Vail
PAC-E-17-07 /Rocky Mountain Power
September 15,2017
IPUC 16*Set Data Request 18
IPUC Data Request 18
Please provide a detailed map of the existing transmission system for Wyoming
identifyingthe individual segments and the segment transmission capacity.
Separately provide a table showing each transmission segment and the monthly
utilization for each of the segments.
Response to IPUC Data Request 18
The Company objects to this request as vague,ambiguous,not reasonably
calculated to lead to the discovery of admissible evidence,and requiring
development of a special study or information not maintained in the ordinary
course of business.Without waiving these objection,the Company responds as
follows:
Please refer to Attachment IPUC 18,which provides a Wyoming system map.
The transmission in East Wyoming is operated jointly by PacifiCorp and the
Western Area Power Authority (WAPA).WAPA owns a percentage of the net
transmission export capacity from East Wyoming and uses that transmission for
their load service.PacifiCorp uses the remaining transmission capacity to serve
native load as well as to export generationfrom East Wyoming to serve load in
other parts of PacifiCorp's service territory.Eastern Wyoming transmission
constitutes lines forming the Western ElectricityCoordinating Council (WECC)
paths TOT 4A and TOT 4B.The two paths'operating limits are interdependent
and are associated with a nomogram.Either path limit is dependent on flow on
the adjacent path,the real-time rating can range between a minimum of
0 megawatts (MW)and a maximum of 1,025 MW.Typically,the real-time rating
centers around 650 MW.
Consistent with the PacifiCorp tariff,firm transmission capacity can only be
committed up to the physical capability of the actual transmission.Likewise,
real-time schedules and actual flow can only be allowed up to the actual
transmission capacity.The current transmission is insufficient to serve the peak
demand of all generationcurrentlyin the area.
The Uxx utilization metrics developedby WECC's Transmission Expansion
Planning Policy Committee (TEPPC)are used to facilitate performance
comparisons among the Western Interconnectpaths.These metrics represent the
percentages of time that the path flow or schedule exceeds 75 percent and
90 percent of its operating transfer capability.The 75 percent utilization level
(U75)was chosen as an indicator of a path that may be considered heavilyused.
The 90 percent utilization level (U90)is an indicator of very heavy path loading.
The utilization factor is calculated using hourly data for a given year to determine
percent of the time path flows is in exceedance of its maximum operating rating.
PAC-E-17-07 /Rocky Mountain Power
September 15,2017
IPUC 1st Set Data Request 18
The table below indicates TOT 4A/4B operating limit (U90)is in exceedance a
third of the time (32 percent of the time)when delivering the existing resources,
including 1,350 MW of Wyoming wind:
Table 1_Eastern Wyoming Transmission Usage
(August 22,2012-August 22,2017)
TOT 4A\4B
Transmission Usage
Schedule
99 percent 11 percent
90 percent 32 percent
75 percent 58 percent
50 percent 90 percent
Recordholder:Jamie Austin
Sponsor:Rick Vail
PAC-E-17-07 /Rocky Mountain Power
September 15,2017
IPUC 16'Set Data Request 19
IPUC Data Request 19
Please provide additional detail and examples related to Mr.Link's testimony on
page 7,lines 18-20 -"At times when wind resources in southeastern Wyoming
are operating near full output,other resources in the area can be re-dispatched to
accommodate PTC-producing wind generation."
Confidential Response to IPUC Data Request 19
When the combined southeastern Wyoming resources,both thermal and
renewable,are producing above the transmission transfer limit,thermal resource
output can be reduced to minimum operating levels to enable increased renewable
resource output.Please refer to the confidential chart below for an example,
which shows hourly wind output,hourly thermal output,and hourly thermal
capacity (in megawatts)based on operational data from March 1,2017.On this
day,thermal output was reduced below maximum capacity to accommodate wind
output.
Confidential information is provided subject to the terms and conditions of the
protective agreement in this proceeding.
PAC-E-17-07 /Rocky Mountain Power
September 15,2017
IPUC 1"*Set Data Request 19
Recordholder:Tom Burns
Sponsor:Rick Link
PAC-E-17-07 /Rocky Mountain Power
September 15,2017
IPUC 16'Set Data Request 20
IPUC Data Request 20
Presupposing a new transmission line between Aeolus and Anticline,would the
60 MVAr synchronous condenser at Standpipe still be required for voltage
stabilization?(Vail,Di.24)
Response to IPUC Data Request 20
The Standpipe synchronous condenser is and will continue to be useful with the
addition of the new Aeolus-to-Bridger/Anticlineline.
Responder:Craig Quist
Sponsor:Rick Vail
PAC-E-17-07 /Rocky Mountain Power
September 15,2017
IPUC 1st Set Data Request 21
IPUC Data Request 21
Please provide all related costs associated with the installation of the synchronous
condenser located at Standpipe.(Vail,Di.24).
Response to IPUC Data Request 21
[BEGINCONFIDENTIAL]
[END CONFIDENTIAL]
Confidential information is provided subject to the terms and conditions of the
protective agreement in this proceeding.
Recordholder:Lori Adams
Sponsor:Rick Vail
PAC-E-17-07 /Rocky Mountain Power
September 15,2017
IPUC 16'Set Data Request 22
IPUC Data Request 22
Please indicate if the Company plans to evaluate the bids through its proposed
Request for Proposal process from the perspective of the utility or from the
perspective of the ratepayer.In other words,will the Company include the
Company's authorized rate of return when evaluating the cost of the Company's
submitted bids for its benchmark projects versus the cost of a Purchase Power
Agreement for a developer owned and operated facility?Please provide an
example of the analysis over the life of the project to compare the benchmark
project to a PPA.
Response to IPUC Data Request 22
PacifiCorp will evaluate all benchmark and market bids and all bid structures (i.e.,
benchmarks,build-transfer agreements (BTA),and power-purchase agreements
(PPA))from the perspective of the customer.The Company will include all
elements of revenue requirement associated with its proposed benchmark
resources,and any market bids proposing projects under a BTA,which will
include return on investment,return of investment,taxes (including any
applicable production tax credit (PTC)benefits),and any on-going operating
expenses.Revenue requirement for a PPA is traditionallycaptured as net power
costs (NPC).The cost of all proposals will be compared to the customer benefits
they provide.Please refer to Confidential Attachment IPUC 22,which describes
PacifiCorp's 2017 Renewable Request for Proposals (2017R RFP)bid evaluation
and selection process along with an overview of the models and key assumptions
that are required.
Confidential information is provided subject to the terms and conditions of the
protective agreement in this proceeding.
Recordholder:Bruce Griswold /Ron Scheirer
Sponsor:Rick Link
PAC-E-17-07 /Rocky Mountain Power
September 15,2017
IPUC 1st Set Data Request 23
IPUC Data Request 23
The Request for Proposal solicitation includes a provision allowingthe Company
to purchase the wind developmentproject under a build-transfer agreement (Link,
Di.13).How will the Company ensure that Customers not be economically
disadvantaged if the Company chooses to purchase the facility?
Response to IPUC Data Request 23
Please refer to the Company's response to IPUC Data Request 22.PacifiCorp will
evaluate all bids,including bids submitted as a build-transfer agreement (BTA),
from the perspective of the customer.The Company's bid evaluation and
selection process will take into account the economic benefits of each proposal
relative to its unique costs.The Company's bid evaluation and selection process
will be done with the oversight of two independentevaluators (IEs)that will
oversee the request for proposals (RFP)process on behalf of the Public Utility
Commission of Oregon and the Public Service Commission of Utah.The IEs will
review the Company's bid evaluation and selection process to ensure that
resource selections are made in accordance with the criteria established in the
RFP.The IEs will evaluate whether any proposed acquisition is likely to result in
delivery of electricity at the lowest reasonable cost for customers and evaluateany
unique risks and advantages associated with the proposed resources.
Recordholder:Bruce Griswold
Sponsor:Rick Link
PAC-E-17-07 /Rocky Mountain Power
September 15,2017
IPUC 16'Set Data Request 25
IPUC Data Request 25
Has the Company quantified the economic tradeoff between reduced wind
capacity factors and transmission investment expense?If so,please provide the
results of the analysis.If not,why not?
Response to IPUC Data Request 25
The System Optimizer (SO)model can choose from a broad range of resource
alternatives when developing least-cost resource portfolios that meet a target 13
percent planning reserve margin (PRM)over a 20-year forecast period.Wind
resources that have lower capacity factors (i.e.,wind resources alternativesin
PacifiCorp's system that are located outside of Wyoming)were available for
selection in the SO model simulations as alternative to meet system needs.In the
Company's economic analysis,the resource portfolios containing the Wyoming
wind resources and the new transmission by the end of 2020 reduce system costs
relative to other resource alternativesin seven out of nine price-policy scenarios.
In these scenarios,the new wind and transmission projects are lower cost than
other resource options.
The resource portfolios developed for each of the price-policy scenarios included
in the Company's economic analysis are provided in the confidential work papers
that accompanied the Direct Testimony of Company witness,Rick T.Link,
specifically the confidential files located in the "SO Model Summary Reports"
folder.Within this folder,files with the letters "EGI"in the file name include data
for simulations that include the new wind and transmission projects.Files with the
letters "EEN"in the name exclude the new wind and transmission projects.There
are "EGI"and "EEN"files for each price-policy scenarios,which are identifiable
by the last two letters in the file name.The first of these two letters represent the
gas price assumptions (i.e.,M =medium,L =low,and H =high)and the second
of these two letters present CO2 price assumptions (i.e.,M =medium,N =zero or
none,and H =high).All of the files in this folder summarize the resource
portfolios for each simulation under each price-policy scenario in the worksheet
named "Portfolio".
Recordholder:Randy Baker
Sponsor:Rick Link
PAC-E-17-07 /Rocky Mountain Power
September 15,2017
IPUC 16'Set Data Request 26
IPUC Data Request 26
Please provide the NPVRR(d)of the project with capacity factors of 20%,30%,
40%,and 50%for the Company's benchmark wind projects using medium gas
price and medium CO2 price assumptions.
Response to IPUC Data Request 26
The Company objects to this request requiring development of a special study or
information not maintained in the ordinary course of business.Without waiving
this objection,the Company responds as follows:
PacifiCorp has not performed the requested analysis.It is important to note that
available wind data collected on and around the benchmark sites,as well as
available performance curve data from competitive market wind turbine generator
equipment suppliers,is expected to provide better decision-making information
than general graduated scale capacity factor assumptions for a given site.
Recordholder:Randy Baker
Sponsor:Rick Link
PAC-E-17-07 /Rocky Mountain Power
September 15,2017
IPUC 13'Set Data Request 27
IPUC Data Request 27
Please provide all supporting documentation for the transmission project cost
estimates by project section (i.e.the 3 projects included in the Aeolus-to-
Bridger/AnticlineLine;and the 3 projects included in the 230 kV Network
Upgrades).(Vail,Di 2)
Response to IPUC Data Request 27
The cost studies for the project contain commercially sensitive information and
are considered highly confidential.Public disclosure of this information before
completion of the competitive bidding process in 2018 could negatively impact
the responses from bidders with potential for the Company to not secure the most
cost-effective proposal.Copies of the cost studies are available,upon notice,for
inspection in Rocky Mountain Power Salt Lake City offices.Please contact Ted
Weston at [phone] to make arrangements for review.
Recordholder:Rick Vail
Sponsor:Rick Vail
PAC-E-17-07 /Rocky Mountain Power
September 15,2017
IPUC 16*Set Data Request 28
IPUC Data Request 28
Please provide all supporting documentation for the benchmark wind project cost
estimates.
Response to IPUC Data Request 28
The requested information is considered to be highly confidential and
commercially sensitive.The Company requests special handling.Please contact
Ted Weston [phone] to make arrangements for review.
Please also refer to the Company's response to IPUC Data Request 8.
Recordholder:Chad Teply
Sponsor:Chad Teply
PAC-E-17-07 /Rocky Mountain Power
September 15,2017
IPUC 161 Set Data Request 30
IPUC Data Request 30
Please provide a copy of PacifiCorp's Energy Vision 2020 strategy.
Response to IPUC Data Request 30
The Company objects to this request as requiring disclosure of information
protected by the attorney-client privilege or attorney work product doctrine.
Without waivingthis objection,the Company responds as follows:
PacifiCorp's Energy Vision 2020 includes the "New Renewable Resources and
Transmission"and the "Wind Repowering"projects included in the preferred
portfolio in the Company's 2017 Integrated Resource Plan.The "Energy Vision
2020"nomenclature was developedto facilitate streamlined communication of
this key set of resource opportunities with stakeholders,and has been used in
responses to media inquiries and other public dissemination of project
information.
Recordholder:Chad Teply
Sponsor:Cindy Crane
PAC-E-17-07 /Rocky Mountain Power
September 15,2017
IPUC 16*Set Data Request 31
IPUC Data Request 31
Please explain what the Company will do with the items procured to meet the 5%
safe harbor benchmark if the projects do not proceed.Will the Company request
customers pay these costs?
Response to IPUC Data Request 31
If regulatory approvals for the Energy Vision 2020 projects are not granted and
the combined new development wind and transmission projects do not proceed,
PacifiCorp will evaluate alternativesto identifythe best use of the safe-harbor
equipment purchased.Options could include deployment as incremental resources
at existing wind projects,transfer for fair considerationto PacifiCorp affiliates for
inclusion in then-qualified production-tax-credit-eligible projects,or selling the
equipment to other parties that are developing new wind projects.
To the extent the safe-harbor equipment is included in a used and useful asset,the
Company would seek recovery of the prudentlyincurred costs.
Recordholder:Chad Teply
Sponsor:Chad Teply
PAC-E-17-07 /Rocky Mountain Power
September 15,2017
IPUC 16*Set Data Request 32
IPUC Data Request 32
Please provide a list of all contracts required to complete the wind and
transmission projects.Please include the names of the contractor,the purpose of
the contract,and estimated cost amounts.
Response to IPUC Data Request 32
Wind
A number of contracts will be required for the new wind projects.Many of these
contracts have not yet been awarded as the procurement process is ongoing,the
Company's 2017 renewable request for proposals (2017R RFP)process is yet to
be completed,and regulatory approvals have not been received.Nonetheless,the
major contracts required to construct the new wind resources will consist of the
following:
Wind turbine equipment supply (safe-harbor purchases).
Wind turbine equipment supply (follow-onwind turbines).
Balance-of-Plant (BOP)Engineer-Procure-Construct(EPC)contracts for the
projects.
Development Transfer Agreement (DTA)(if applicable to the project).
Transmission Interconnection.
Owner's Engineer.
The Company's current estimates for these major contracts for the yet-to-be
finalized benchmark proposals,are considered to be highly confidential and
commercially sensitive.The Company requests special handling.Please contact
Ted Weston [phone] to make arrangements for review.
Transmission
The transmission line contract will require several major contracts to be placed.
The Company's current estimates for these major contracts for the yet-to-be
finalized benchmark proposals,are considered to be highly confidential and
commercially sensitive.The Company requests special handling.Please contact
Ted Weston [phone] to make arrangements for review.
Recordholder:Rick Vail and Chad Teply
Sponsor:Rick Vail and Chad Teply
PAC-E-17-07 /Rocky Mountain Power
September 15,2017
IPUC 1"*Set Data Request 33
IPUC Data Request 33
In reference to Company witness Larsen,please provide all work papers that were
used to develop Exhibit 27 and Exhibit 28.
Response to IPUC Data Request 33
The confidential workpapers supporting the Direct Testimony of Company
witness,Jeffrey K.Larsen,and used to develop Exhibit No.27 and Exhibit No.28
were provided with the June 30,2017 filing.The file name is "CONF JKL
Exhibits 27-29 EG &New Wind ID 6.28.17."In preparing this response,the
Company noticed that the exhibit numbering of the individual excel tabs refer to
the exhibits as 28-30,rather than 27-29.A corrected file is provided as
Confidential Attachment IPUC 33.
Confidential information is provided subject to the terms and conditions of the
protective agreement in this proceeding.
Recordholder:Terrell Spackman
Sponsor:Jeff Larsen